IR 05000352/1989006
| ML20247C911 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/07/1989 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247C899 | List: |
| References | |
| 50-352-89-06, 50-352-89-6, 50-353-89-06, 50-353-89-6, GL-85-01, GL-85-1, GL-86-10, IEIN-84-09, IEIN-84-9, NUDOCS 8903300311 | |
| Download: ML20247C911 (18) | |
Text
_
._. _
_ _ _ - _
'
f
-
.
.
,
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-352/89-06 Report Nos. 50-353/89-06 50-352 Docket Nos.
50-353 License Nos. NPF-39 and CPPR-107 Priority Category C and B
-
Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station, Unit 1 & 2 Inspection At: j_imerick, Pennsylvania Inspection Conducted: January 23-27, 1989
/
/
/
&M M /f/y Inspector:
/
N. G. Krasopoulos, R6 actor Engineer date '
Also participating and contributing to the report were:
R. Hodor, Mechanical System Specialist, BNL K. Parkinson Electrical System Specialist, Sonalyst Corp.
Approved by:
8 7 f7 C. J. Ahderson, Chief, Plant Systems date Section Inspection Summary:
Inspection on January 23-27, 1989 (Combined Inspection Report Nos. 50-352/89-06 and 50-353/89-06)
Areas Inspected:
Special, announced team inspection of the safe shutdown capability of the plant in the event of a fire.
Results: One violation of the Limerick Unit 1 License Condition C.3 requirements was identified.
(The wall separating the Unit 1 cable spreading room from the Unit 2 cable spreading room was not 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated because it included a door that was not fire rated.)
8903300311 890320 PDR ADOCK 05000352 Q
,
...
_
_ _ _ _ _ _ _ _ _ _ _ _ _ - -. - - - - - - - - - -
- - - - -
-
m
. _ - - - - - - - - -. - - - _ - _ - - _ - - - - _ _ - - _ - - _ - _
--
,
,
.-
.
.
,
.
.
Details 1.0 Persons Contacted 1.1 Philadelphia Electric Co. (PECO) and Contractors
+*M. McCormick Jr., Plant Manager
+*G. Sproat, Project Manager
+*A. MacAinsi, Manager Quality
,
l
+*D. DiPaolo, Superintendent Unit 2 QA
+*D. Neff, Licensing Engineer
- K. Humma, Assistant Project Contractor Engineer (Bechtel)
+*R. Slaughter, Lead Project Quality Engineer (Bechtel)
- M. Drucker, Lead Resident Engineer (Bechtel)
+*C. Endriss, Regulatory Engineer
+*D. Feaster, Fire Protection Supervisor
- G. Reid, Facilities Branch - Nuclear Engineering
+*J. Halt, Electrical Engineer
+*D. Spamer, Electrical Engineer
- G. Englehardt, Project Manager
+*W. Boyer, Manager Engineering Services
+*R. Lees, Manager Electrical Engineering
+*Wm. Brady, PEC0
+*B. Posta, Assistant Project Engineer
+*G. Tepper, Electr' cal Construction Engineer
- J. Corcoran, Startup Superintendent Support
+*P. Arney, Quality Assurance
+*E. Grant, Licensing Engineer
.
.
+*G. Stewart, Engineer l
- R. McKrush, Sr. Licensing Engineer
+*L. Ewing, Quality Assurance
'{
l
+ B. Walrod, Mechanical Engineer (Bechtel)
l
+ B. Kaucher, Mechanical Engineer (Bechtel)
+ D. Honan, Licensing l
+ S. Vail, Group Leader Nuclear (Bechtel)
!
+ S. Walter, Electrical (Bechtel)
l
+ P. Zavadiuker, Electrical Engineer (Bechtel)
+ G. Leitch, Vice President, Limerick
+ W. Ullrich, Startup Manager 1.2 Nuclear Regulatory Commission (NRC)
+*T. Kenny, Sr. Resident Inspector Limerick 1
+*B. Gramm, Sr. Resident Inspector Limerick 2
+*R. Fuhrmeister Resident Inspector Limerick 2
+*L. Scholl, Resident Inspector Limerick 1
+*J.
Linville, Section
+ J. Durr, Branch Chief i
- Denotes those present at exit interview.
+ Denotes those present 3t management meeting.
_
___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ - -
v t
.
.
.
.
'
.
.
2.0 Purpose
?
This inspection was performed to verify the licensee's ability to safely shutdown both Units in the event of a fire.
The inspectors effort was
!
concentrated on Unit 2.
Unit 1 was previously inspected by the NRC in i
this area.
However, certain areas of the Unit 1 safe shutdown capability
'
were reviewed during this inspection primarily because they were common to both units.
3.0 Background Limerick Nuclear Station Units I and 2 are required to have the ability to safely shutdown in the event of a fire. This requirement was derived
)
from licensing commitments made during the review of the Stations's Fire Protection Program.
This review was documented in the Safety Evaluation Report (SER) dated August 1983 and Supplements 2 and 4, dated October 1984 and May 1985, l
respectively.
4.0 Correspondence l
The correspondence between the licensee and the NRC concerning licensee commitments and compliance with these commitments was reviewed by the inspection team in preparation for the site visit.
These commitments are described in the licensee's Fire Protection Evaluation Report Revision 10 and Section 9.5.1 of the Final Safety Analysis Report (FSAR).
5.0 Management Meeting A management meeting was held at the licensee's Limerick facilities on January 23, 1989. A list of attend 3es to that meeting appears in Section 1 of this report. The material distr buted at the meeting by the. licensee is included as Attachment 1.
l This meeting was held at the licensee's request to discuss several Fire Protection / Safe Shutdown deficiencies and the work being done to address these issues.
The licensee stated that the deficiencies were identified as a result of the lessons learned from the safe shutdown review conducted at Peach Bottom.
The licensee also stated that a self-assessment program has been initiated to identify the root causes and the corrective actions for the deficiencies.
l
_ - -
. _ _ _ _ _ _ _ _ _ _ _ -
_
-
.
,
.
.'
- -
..
T M licensee did not discuss all of the specifics of the corrective actions since the scope of the work has not been fully established.
However, the licensee stated that at the completion of Phase II of the self assessment, the NRC will be informed of the results of this evalua-tion.
This is scheduled for April 14, 1989.
6.0 Post-Fire Safe Shutdown Capability The licensee's safe shutdown analysis provided in the FPER, states that systems needed for hot shutdown and cold shutdown are redundant and that one of the redundant systems needed for safe shutdown would be kept free of fire damage.
The FPER describes five safe shutdewn methods designated as methods A, B, C, D and R.
For a fire in any fire area, at least one of the methods will be available.
For a fire in the control room, cable spreading rooms, or the auxiliary equipment room, method R (also called the remote shutdown method) will be used.
For other plant areas, at least one of the other four methods (A, B, C or D) will be available.
The following table summarizes the differences between the five methods.
Depres-Shutdown Method Reactor Make-up surization Heat Removal A
RCIC ADS RHR "A" in suppression pool cooling and shutdown cooling modes B
HPCI ADS RHR "B" in suppression pool cooling and
,
shutdown cooling modes C
RHR "C" in ADS RHR "A" in suppression LPCI mode pool cooling and shutdown cooling modes D
RHR "D" in ADS RHR "B" in suppression LPCI mode pool cooling and shutdown cooling modes R (from outside RCIC ADS RHR "A" in suppression the C.R.)
pool cooling and shutdown cooling modes To achieve shutdown when the high pressure systems are used (Methods A, B, and R) the licensee's analysis states that the MSIV's are closed and the l
Reactor Core Isolation Coolant (RCIC) system or the High Pressure Coolant Injection (HPCI) system supply make up water to the reactor.
Excess steam generated by the reactor is removed to the suppression pool by the Safety Relief Valves (SRVs).
Suppression pool temperature is maintained by the Residual Heat Removal (RHR) system operating in the Suppression Pool Cooling
_
. ____
_
--
..
,
.-
.
,,
.
...
,
,
mode. Shutdown cooling is accomplished by using the. Automatic Depressuri-zation' System (ADS) to depressurize the reactor and the shutdown cooling-mode of.the RHR system 1: ' hen used to maintain the reactor in. a cold.
.
shutdown condition.
!
To achieve shutdown when only the Low Pressure Coolant Injection Systems; are available, the: licensee would use shutdown Methods C or D.
The analysis specifies that the reactor would be depressurized by the ADS.
system and discharging steam into the suppression pool.
Heat from the suppression pool would be removed by the RHR system in the Suppression Pool Cooling mode. When the. reactor pressure decreases to 75 psig, the RHR system would be switched ~from the suppression pool cooling mode to the shutdown cooling mode.
The team' observed that the licensee did not have a plant specific analysis:
.i to verify adequate core coverage when the ADS is actuated to depressurize.
the reactor. The licensee committed to provide the NRC with a plant specific analysis addressing.this issue and a. time-line of'the activities involved from the timeHof ADS system actuation, to the time, the LPCI system can begin injecting coolant in the vessel.
6.1 Safe Shutdown Procedures for Methods A, B, C and D The licensee has four separate' procedures, listed below, correspond-
!
ing to methods A, B, C and D, for shutdown of the plant from the control room in the event of a plant fire.
The team. reviewed these procedures'for technical adequacy:
.
.
i Procedure.SE-8, Attachment A, Safe Shutdown Method A, Revision 3
.j
i Procedure SE-8, Attachment B, Safe Shutdown Method B, Revision 3
Procedure SE-8, Attachment C, Safe Shutdown Method C, Revision 3
Procedure SE-8, Attachment D, Safe Shutdown Method D, Revision 3
6.2 Remote Shutdown - Method R Method R would be used if a fire damages any of the following
areas: the Control Room, the Cable Spreading Room or the Auxiliary
Equipment Room.
For a fire in any of these areas, the shutdown systems would be controlled from the remote shutdown panels.
To.
ensure that the systems are independent of the fire areas involved, the licensee installed isolation switches that would transfer control I
of the shutdown equipment to the shutdown panel.
The shutdown methodology and systems used by the licensee were reviewed. No deficiencies were: identified.
However, the procedures to shutdown both units from outside the control room were not reviewed because
l
.. _ _ _... _ _ _ _ _.. _
_ _ _ _
.__..._____._____.___________._m_
_ _ _ _ _ _ _ _ _ _ _ _ _
_____._______J
v
.
..
'
-
.
.
,,
.
.
they are still being developed. The team noted that Unit 1.has inplace procedures to_ shutdown the unit from outside the control room. These procedures were previously reviewed by'the NRC.
The team informed the licensee that the safe shutdown'proce'dures addressing the simultaneous shutdown of both units and control room-evacuation, should be complete prior to the issuance of the Limerick Unit.2 operating license.
This. item is unresolved pending.
completion of the. procedures by the licensee and review by the NRC.
(50-352/89-06-01 and 50-353/89-06-01)
7.0 Inspection Methodology The' inspection' team examined the licensee's capabilities for. separating and protecting equipment, cabling and associated ~ circuits necessary to achieve and maintain hot and cold shutdown conditions.
The following functional requirements were reviewed for achieving and maintaining hot and cold shutdown:
Reactivity control
Pressure Control
Reactor. coolant makeup
Support Systems
Process monitoring j
The inspection team examined the licensee's capability to achieve and maintain hot shutdown and the' capability to bring the plant to a cold shutdown condition in the event of a fire in areas where remote shutdown capability is provided. The examination included a review of the drawings-
for the remote shutdown capability and a review of the procedures for-I achieving'the remote shutdown.
Drawings were reviewed to verify.
'
electrical independence from the areas'of concern.
Procedures were l
reviewed for general content and feasibility.
'
The team also inspected the fire detection and suppression systems and i
the degree of physical separation between redundant trains of Safe
.
-!
Shutdown' Systems (SSSs).
The team review included an evaluation of the I
susceptibility of the SSSs for damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
!
!
.
c
_ _ _ _ _
.
. _ _
__
___
__
_.
_ _ _ _
_ _ ____ _ _ _
, _ -
_ _ _ - _ _ _ -
-
.
. -.
' 1
,.
-. -
-
.
,.
., -
-
a
.
'
y The inspection team examined the licensee's fire protection features provided to maintain one train of equipment needed for safe. shutdown free:
of fire damage.
Included in the scope of.this effort were fir _e area boundaries:
including walls,' floors and ceilings, and fire protection of openings such as fire doors,~ fire dampers, and penetration seals. The results of this review are discussed below.
'j The team observed that the door installed on the fire barrier separating the Unit I cable spreading room from the Unit 2 cable spreading room was J
modified in a way that' degraded its fire barrier. function.
The modifica-tion included the addition of an electromagnetic latch without a positive t
l latching mechanism. The door observed by the team would.open.when magnetic--
contacts released at the push of a button..The team noted that this' door:
,
L is not fire rated because a, fire on either side ~could cause loss of power i
to the door thus leaving the door open when the door is required to be
-]
closed.
~
This modification was performed prior to Unit 1 operation. 'Since that time, modifications are reviewed for their impact on the Fire Protection'
.
.
system. Thus, a similar mistake would b'e less likely to occur.
,
The licensee stated that.although there was a fire watch in the Unit I cable spreading room at the time of the inspection (for reasons other than this deficiency) they could not confirm the prese~nce of a fire watch from the time the deficient' fire door had been installed.
The Limerick Unit 1 Facility Operating Licen_se, paragraph C.(3) Fire Protection specifies that...
the licensee shall maintain in.effect all provisions of the approved Fire Protection Program.as described.in the Fire Protection Evaluation Report (FPER) through Revision 6.
The FPER in Section 3.1.1, item '.o. 38, states that Fire Barriers rated for.3-hours are provided to separate Unit 1 structures from Unit 2 structures.
Those structures that are common to both reactor units such as the control.
structure are. separated from the adjacent structures by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire.
barriers. The lack of a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire door on the wall separating the Unit I cable spreading room from the Unit 2 cable spreading room represents a violation of the above mentioned requirements.
(_50-352/89-06-02)
7.1 protection for Associated Circuits Appendix R,Section III.G, requires that protection be provided for associated circuits that could prevent operation or_cause maloperation of redundant trains of systems necessary for safe shutdown. The circuits of concern _are generally. associated with safe shutdown circuits in one of three ways:
_ - _ _ _____ ____ -
. - _ - _-_ _ _ _ _
-
-
r 19I 4'
'
-
.
,
,,
.
.
,
,
Common bus concern a
Spurious' signals-concern
Common enclosure concern
The. associated circuits were evaluated by the team for these concerns.
Power, control, and instrumentation circuits were examined for potential problems. A sampling basis was used in making thel examination.
The samples were selected based on the most important components'used in Methods A, B, C and D of safe shutdown.
<
' 7.2. Common Bus Concern The common bus concern is found in circuits either safety related or non-safety related where there is a common power, source with
-
shutdown equipment and the power source is not electrically protected from.the circuit of concern.
The team examined the protection of several circuits. This included a review of'the coordination of fuses, circuit breakers, and relays.
The team noted that the licensee did not have an analysis to ensure ~
i that safe shutdown equipment was protected from high impedance faults.
The licensee during the Management Meeting discussed in.
?
.Section 5.0, acknowledged that this was a deficient' area that they
are currently addressing.
'
"
The team also noted that the licensee does not have in place a
.
,
program to control fuse replacement.
The licensee stated that such
a program is currently being developed.
This program will be similar to the program established.at Peach Bottom that the NRC-reviewed and found acceptable..The team informed'theLlicensee that the-high impedance fault concern and fuse replacement concern are collectively classified as an Unresolved Item (50-352/89-06-03 and 50-353/89-06-02).
7.3 Spurious Signals Concern
'
.:
The spurious signal concern is made up of 2 items:
False motor,' control, and instrument indications can occur such
as those encountered during 1975 Browns Ferry fire. These could be caused by fire initiated grounds, short'or open circuits.
Spurious operation of safety related or non-safety related :
components can occur that would adversely affect shutdown capability (e.g., RHR/RCS isolation valves).
The review of the licensee's analysis addressing the spurious signal concerns identified the following unacceptable condition:
.i
-
l
.=6 M..
... _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_,____- _ __
_ _ - - - - - _ _ _ -..
- -. _ - _ -
-_- - _ _
...
,-
.
.'
-
..
f High Low Pressure Interfaces
- The licensee'has analyzed.the high-low pressure interfaces and
- documented this analysis in the FPER..The review of.this'
.
analysis determined that it was deficient in that the protection
~
- of the high/ low pressure interfaces was'not demonstrated. JThe licensee acknowledged this during the management meeting.t :They stated that they' are aware of the deficiencies that exist with the protection of high/ low pressure interfaces and committed to-resolve the issue prior to the issuance of the operating license.
This. item is Unresolved (50-353/89-06-03).
8.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain-whether they are acceptable items, violations or deviations.
9.0 Exit' Interview-
~
The inspector met with licensee management representatives (see Section:
1.0 for attendees)'at the conclusion of the inspectionfon January 27, 1989. The-inspector also' confirmed with the. licensee that the report will not contain any proprietary-information. 'The licensee.
agreed-that the inspection report may be placed in the Public Document Room without-prior licensee review for proprietary information
.
1.
At no time during.this inspection was written material provided to the
'
licensee by the inspector.
'
- - -
- _ _ -
-
,
u
.
,
.
..
.*
,
.
'I
%
l ATTACHMENT 1
'
O d
LIMERICK GENERATING STATION SAFE SHUTDOWN ANALYSIS i
j
'
INTRODUCTION
-
'
PURPOSE:
1.
Inform Region I of the status of PECo work to ensure the validity of the LGS SSD Analysis
-
2.
Entrance meeting for the Unit 2 SSD analysis l
audit by NRC Region I
l
)
l-TOPICS:
1.
Background 2.
Basis for re-examining the SSD Analysis 3.
PECo' Self-Assessment Plan for the SSD Analysis: Phases I, ll, and 111 4.
Continuing the Deportability Process 5.
Conclusion
,
PST8901A
- _ - _ _ _ - _ _ _ _ _ _
-.
- - _ _
_
v
',
-
.
..
.
.
.
,
.
.
~
.
'
BACKGROUND
'
1982-84 LGS Unit.1. SSD:- analysis p'erformed
- 1985-88 LGS Unit 2 SSD analysis performed
- Unit: 2 SSD analysis. performed identically to' Unit 1
.
SSD analysis
'1986 PECo" performed re-analysis for PBAPS SSD'
l capabilities
- Sept. 1987 - N ov. 1988 PECo review of the ~' LGS SSD analysis for lessons. learned during PBAPS Appendix R work
- Dec. 1988 PECo Self-Assessment initiated l^
l l
l P ST 8 901B
).
!
. '. ','.
j
,
-
,
'
.
.1 i
'
BASIS FOR RE-EXAMINING THE LGS SSD ANALYSIS
'
s Through 1987, only four reportable co'nditions had l
'
-been identified with respect to the SSD analysis
'
85-57 85-87 86-55 87-55
- In each case, root cause was determined to be isolated errors
%.
Since the PBAPS Lessons Learned Review was initiated,
q i
four additional reportable conditions on the SSD
analysis have been identified j
88-31 88-39 88-40 89-02 I
- In LER 88-31 & subsequent responses', PECo committed
,
l to identify root cause and corrective actions to prevent recurrence PECo recognized the need to perform a formal Self-
Assessment to resolve concerns regarding:
- The increasing number of issues being identified
'l i
- The validity of previous root cause and corrective l
action determinations
- Differences in methodology & assumptions between PBAPS and Limerick h
,
PST 8 9 01E l
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ -
m
-
, i
.
<
-
.
.
i
.
REPRESENTATIVE PEACH ' BOTTOM " LESSONS LEARNED"
1SSUE LIMERICK STATUS j
Valid Process Parameters /
Evaluation in Progress
Synergistic Ef fects.
~
Isolation Prior To Fire Changes identified To Date
Damage Will Be Installed Prior To Unit 1 Startup/ Unit 2 Fuel
]
Load Multiple High Impedance Limerick Evaluation To Follow
Faults Peach Bottom Resolution
.
High-Low Pressure Limerick Evaluation To Follow f
{
Interface Peach Bottom Resolution Additional Instrumentation Changes Will Be Installed
Per IEN 84-09, GL 85-01, Prior To Unit 2 Fuel Load; and GL 86-10 Unit 1 Schedule Under Development
.
'
Time-Manpower Analyses in Progress
To Support Manual Actions
PST8901L
- _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _. - - - _ _ _ - - _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _.
. _ _ - _ _ - - - _ _ - _ _ _ _ - _ _ - _
m
..
..
-
-
-
.
.
.
-
.
__
l PECo SELF-ASSESSMENT OF THE LGS SAFE SHUTDOWN
'
ANALYSIS PECo initiated a three phased assessment of the LGS SSD analysis PHASE 1
- Performed by the A/E (Bechtel) with of f-project personnel
- Retrospectively assessed adequacy of original FPER SSD meth'odology, documentation and implementation Preliminary Bechtel Conclusions:
- Original methodology is acceptable, but should be upgraded to reflect PBAPS Lessons Learned
- Implementation was correct within scope of assessment
- Upgrade of documentation would improve auditability and usefullness as design basis documentation i
!
P ST 8 9 01F
-......... -.. -.
....
-.....
_
--
- - -
<
. ~ *
.;
.-
.
,
^
'
i
!
...
>
'
I l.-
.PECo SELF-ASSESSMENT OF THE LGS ~ SAFE SHUTDOWN
-
!.
ANALYSIS
.'
1
'
PHASE ll
.
' To be conducte'd by PECo personnel and independent
'
snsultant s
Purpose is to:
!
'
- Independently validate the results of Phase 1 i
- Determine root cause for the reportable conditions
- Define scope and schedule for corrective I
actions
.l Sampling Techniques may be utilized
Expected - completion between 3/3/89 and 4/14/89,
depending on extent of sampling effort-NRC will be provided results
,
P S T B 9 01G
-
- _ _ - _ - _ - _ _ _ _ _ _ _ _.
_. -.
.....
- .
...
-
.
..
.
,
.
-
.1 l
!
i i
!
'
PECo SELF-ASSESSMENT. OF THE LGS SAFE SHUTDOWN
'
ANALYSIS
.
PHAS$ 111
- Phase -ill will..be the implementation 'of ' corrective a
actions identified in Phase 11
{
J
- Scope. and schedule cannot be identified until completion of Phase 11
,
- Scope of work is expected to. include;
,
- Correct specific deficiencies identified
- Upgrade the LGS SSD program for. any deficient
<
programmatic-areas identified
- Make any _ necessary. changes to Licensing
{
Documents (FSAR, FPER)
'
- Pica for implementation of design changes if necessary
.
.
l
!
P ST 8 901H
- - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - - _ - - _.
. _.. _ _ -
~
.,
s.. s,
.
'
-
.
.
~
.
CONTINUING THE ' DEPORTABILITY PROCESS -
'
.. PECo expects that' additional reportable conditions will' be identified during the conduct of this
' Self-Assessment
- PECo. will. continue to keep the NRC apprised of any-new deportability concerns identified-
.
'
l l
l
}
.
PST89014
m-
.
_
____---
./ 'g
-
.
.
.
.
~
.
..
..
'
CONCLUSION
'
Information available to date supports 'PECo's I
+
confidence in the original SSD Analysis and its implementation at Units 1 and 2, as described in the FPER PECo has work to do to implement Peach Bottom
. Appendix R Lessons Learned et Limerick, and has l
implemented a program to do so I
i Following completion of Phase 11, PECo will apprise
the NRC of its Corrective Action Plan
I l
PST 8 901J
!
L_____._____